Author Archives: Dr. Nicholas Garrett

Dr. Nicholas Garrett is a Director of RCS Global and an internationally recognized expert in the company’s six core work areas: supply chain due diligence and conflict minerals compliance, transparency, artisanal and small-scale mining, responsible supply chains, human rights and public policy and institutional reform. He has worked on more than 50 projects for over 10 years and regularly advises a range of clients, including AngloGold Ashanti, AVX, the EITI, Nokia, the Organization for Economic Cooperation and Development, Trafigura, the World Bank, and the World Gold Council, the British, German, Japanese and U.S. governments, the World Wide Fund for Nature (WWF) and World Vision. MetalMiner welcomes his perspective on conflict minerals compliance.

A lack of clarity on how and when key provisions of Dodd-Frank Wall Street Reform and Consumer Protection Act will be fully implemented is leaving downstream businesses in limbo — many of whom are looking to enhance their minerals sourcing compliance.

Conflict Minerals Flowchart

RCS Global’s simple IPSA flowchart. Source: RCS Global.

When passed, the implications of Dodd-Frank 1502 looked game-changing, significantly increasing the obligations on downstream companies using “conflict minerals,” but following an upheld appeal, the requirement to undertake an audit under Dodd-Frank 1502 is in stasis, leaving many companies either unsure as to how to validate their compliance obligations linked to the bill, or whether they should even attempt to validate at all.

MetalMiner Price Benchmarking: Current and Historical Prices for the Metals You Buy

Nevertheless, at some point in the not too distant future, more than 6,000 Securities and Exchange Commission issuers producing products containing tantalum, tin, tungsten and gold — better known as the 3TG — will be forced to make significant efforts to improve transparency, monitoring and oversight of their supply chains, and ultimately determine the source of the materials in a vast range of everyday products. Read more